FEIS - Tahoe Regional Planning Agency
FEIS - Tahoe Regional Planning Agency FEIS - Tahoe Regional Planning Agency
RESPONSE TO COMMENTS ON THE DEIS B o u l d e r B a y C o m m u n i t y E n h a n c e m e n t P r o g r a m P r o j e c t E I S (careful design and construction). The disadvantages were weighed against the advantages during the planning, design and engineering phases of the Project. TRPA reserves the right to require green roofs as a condition for project permitting. Comment 137-h: Comment Summary - The conclusions in Sections 2 and 4.3 that water quality benefits result from reduced traffic due to mass transit/Alternative transportation, yet costs/sustainability of mass transit funding are not analyzed. Need to analyze funding for maintenance and monitoring of drainage improvements and analyze impacts in the absence of project funding. How is long-term funding assured? Would TRPA or other agencies be responsible if funding doesn't exist? The relationships between reductions in traffic and improvements in air quality and water quality are well documented in the scientific and regulatory communities. The analysis for impact HYDRO-1 draws upon this general understanding but does not make absolute statements about the benefits because they are difficult to measure at the project-level. Because the proposed stormwater treatment systems are regional, Boulder Bay has submitted a draft agreement to TRPA committing the Project to funding the construction of these systems and participation in EIP Project 732 and for shared cost of long-term maintenance. This agreement between Boulder Bay, LLC and Placer County will be finalized during approval and permitting of the selected Alternative. See mitigation measure HYDRO-1 for explanation of funding for upgrade of proposed systems and maintenance. TRPA and NDEP have the regulatory authorities for compliance with Regional and State discharge limits. Regarding the request to analyze funding costs and sources, TRPA is only obligated to find that mitigation measures have been required in, or incorporated into, a project which will avoid or substantially lessen identified significant impacts, and these findings must be supported by substantial evidence in the record of the agency’s proceedings (for CEQA purposes, see Title 14 of the California Code of Regulations, §15091(b)). There is no requirement that an agency must describe in the document how mitigation measures are financially feasible. Please see response to comment 54. Comment 137-i: Comment Summary - Since the DEIS fails to evaluate the costs of maintenance and loss of efficiency of containment/infiltration elements, it is uncertain if these elements will be able to capture the amounts calculated. Revise the DEIS to determine if the 20-year 1-hour storm can be captured if the underground galleries are clogged. The comment that proposed stormwater treatment systems will fail without proper maintenance is noted. Appropriate inspection, operation and maintenance of the systems are a condition of project permitting. The commenter requests revision to the DEIS but does not provide suggested methods for analysis. Given that the Project will be required to submit and execute the Inspection, Maintenance and Monitoring Plan (SP-10) and perform post-project stormwater monitoring, the potential for clogging of the proposed system is not significant. Comment Letter 150 – Cash, Rich, 01/28/2010 Comment 150-a: Comment Summary - Kings Beach and Placer County should put four lanes with their roundabouts, rather than two in order to prevent gridlock. Comment noted. Comment appears to refer to the Kings Beach corridor improvement project which is not a part of the Boulder Bay Project. PAGE 8- 56 HAUGE BRUECK ASSOCIATES SEPTEMBER 8 , 2010
RESPONSE TO COMMENTS ON THE DEIS B o u l d e r B a y C o m m u n i t y E n h a n c e m e n t P r o g r a m P r o j e c t E I S Comment Letter 169 – Alexander Jr., Mark, 01/31/2010 Comment 169-a: Comment Summary - Building height impacts on snow/ice melting on new Lakeview/Stateline road alignment. Appendix AE provides a shadow study for Boulder Bay buildings under Alternative C. The simulations document that the Stateline, Lakeview and realigned Wassou roadways will be subject to afternoon sunlight year-round. Comment Letter 171 – Clark, Loren, Placer County, Community Development Resource Agency, 02/01/2010 Comment 171-a: Comment Summary - The Project will have significant, long-term impacts on affordable housing, transit, and public services in Placer County. Alternatives C and D provide a portion of affordable housing demand onsite. Although this does not provide enough housing for all new employees, it provides housing and also transit service for employees residing in more affordable areas such as Truckee and the Reno area. Communications with local public service providers that serve the Project site have not indicated significant, long-term impacts will result. Comment 171-b: Comment Summary - The EIS does not describe temporary or permanent workforce housing. The designs for Alts. B, D, and E are inadequate. The Project needs to provide housing for 50% of new employees. Chapter 4.11 of the DEIS analyzes employment and the demand for workforce housing. While Placer County maintains a requirement for project’s to provide an opportunity for housing 50% of new employees, TRPA and Washoe County do not have a similar requirement. The DEIS concludes that impacts to workforce housing demand are less than significant because of the large pool of currently unemployed workers in the leisure and hospitality section. Alternative A does not require additional employees because no changes would occur to the project area. Alternative B would increase the gaming floor area to the maximum amount of space certified by the NTRPA and would result in up to 14 new employees, which is not considered to be substantial when considering the availability of unemployed employment candidates who are local or living in a variety of nearby communities. Alternative E does not propose any onsite employee housing, but would add 54 employees. Alternative D would provide 9 affordable units able to house 41 persons, but more likely 27 employees. As a result, Alternative D would provide housing for approximately 33% of the estimated employment growth of 83 new employees. Alternative C would provide 14 affordable housing units able to house 57 persons, but more likely 38 employees. This conservative estimate would provide housing for 51% of the estimated employment growth of 74 new employees. Comment 171-c: Comment Summary - The Alternative Transportation Plan in App. F is underfunded for Placer County, and a new mitigation measure should be added to address appropriate fees. Please see response to comment 137-h. Comment 171-d: Comment Summary - Speedboat Beach recreation mitigation needs to include measures for additional trash removal. SEPTEMBER 8 , 2010 HAUGE BRUECK ASSOCIATES PAGE 8- 57
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RESPONSE TO COMMENTS ON THE DEIS<br />
B o u l d e r B a y C o m m u n i t y E n h a n c e m e n t P r o g r a m P r o j e c t E I S<br />
Comment Letter 169 – Alexander Jr., Mark, 01/31/2010<br />
Comment 169-a: Comment Summary - Building height impacts on snow/ice melting on new<br />
Lakeview/Stateline road alignment.<br />
Appendix AE provides a shadow study for Boulder Bay buildings under Alternative<br />
C. The simulations document that the Stateline, Lakeview and realigned Wassou<br />
roadways will be subject to afternoon sunlight year-round.<br />
Comment Letter 171 – Clark, Loren, Placer County, Community Development Resource<br />
<strong>Agency</strong>, 02/01/2010<br />
Comment 171-a: Comment Summary - The Project will have significant, long-term impacts on<br />
affordable housing, transit, and public services in Placer County.<br />
Alternatives C and D provide a portion of affordable housing demand onsite.<br />
Although this does not provide enough housing for all new employees, it provides<br />
housing and also transit service for employees residing in more affordable areas such<br />
as Truckee and the Reno area. Communications with local public service providers<br />
that serve the Project site have not indicated significant, long-term impacts will<br />
result.<br />
Comment 171-b: Comment Summary - The EIS does not describe temporary or permanent workforce<br />
housing. The designs for Alts. B, D, and E are inadequate. The Project needs to<br />
provide housing for 50% of new employees.<br />
Chapter 4.11 of the DEIS analyzes employment and the demand for workforce<br />
housing. While Placer County maintains a requirement for project’s to provide an<br />
opportunity for housing 50% of new employees, TRPA and Washoe County do not<br />
have a similar requirement. The DEIS concludes that impacts to workforce housing<br />
demand are less than significant because of the large pool of currently unemployed<br />
workers in the leisure and hospitality section. Alternative A does not require<br />
additional employees because no changes would occur to the project area. Alternative<br />
B would increase the gaming floor area to the maximum amount of space certified by<br />
the NTRPA and would result in up to 14 new employees, which is not considered to<br />
be substantial when considering the availability of unemployed employment<br />
candidates who are local or living in a variety of nearby communities. Alternative E<br />
does not propose any onsite employee housing, but would add 54 employees.<br />
Alternative D would provide 9 affordable units able to house 41 persons, but more<br />
likely 27 employees. As a result, Alternative D would provide housing for<br />
approximately 33% of the estimated employment growth of 83 new employees.<br />
Alternative C would provide 14 affordable housing units able to house 57 persons,<br />
but more likely 38 employees. This conservative estimate would provide housing for<br />
51% of the estimated employment growth of 74 new employees.<br />
Comment 171-c: Comment Summary - The Alternative Transportation Plan in App. F is underfunded<br />
for Placer County, and a new mitigation measure should be added to address<br />
appropriate fees.<br />
Please see response to comment 137-h.<br />
Comment 171-d: Comment Summary - Speedboat Beach recreation mitigation needs to include<br />
measures for additional trash removal.<br />
SEPTEMBER 8 , 2010 HAUGE BRUECK ASSOCIATES PAGE 8- 57